We are in the process of converting to a new account origination system. As part of the conversion we have reviewed all the options there are to us for customer relationships. Two relationships that have been identified and we are not currently using are ATTN: and ICO (for mail to be sent to the attention of someone specific and in care of someone specific).

The question was raised about OFAC. Should we be running OFAC on mail receipients IF they do not have a relationship with the bank? Our practice has been to run all cashier checks payees and we also run all payees that are paid through AP. Why would it be any different for mail?

Thoughts? Guidance?

If you want to dig in to deeper detai and your system/personnel supports it, that is fine. However, unless the ATTN or ICO person is an owner, they are a mere agent and you don't really need to do OFAC on them as part of CIP/AML. Please be careful what you start because examiners have been known to turn something like this into an expectation.